SNT exceptions
The first-party (d4A) and pooled (d4C) special-needs-trust exceptions to SSI resource counting — verified against the trust type and its governing terms before any distribution is cleared.
The most rigorous POMS-grounded disbursement review a professional fiduciary can rely on.
BenefitGuard returns a dated, cited Determination Memo within one business day — a Benefit-Impact Projection, a Restructuring Alternative where relevant, and a licensed attorney's Certified Opinion on demand — every request measured against the letter of the SSA POMS and the ABLE statute before it goes back to you to decide.
Grounded in SSA POMS SI 01120.200 and IRC §529AFirst-party (d4A) and pooled (d4C) SNT exceptions, checkedISM and presumed-maximum-value rules, computedAttorney Certified Opinion on novel or high-value casesDetermination Memo within one business day
Why disbursements go wrong
One month lost is a month lost — no appeal reverses a benefit period already gone.
Every SNT or ABLE disbursement must be individually checked against a narrow, unforgiving federal rule set — and most fiduciaries have no dedicated benefits-compliance specialist reviewing every request before they approve it.
A single unsafe distribution can suspend SSI and trigger a retroactive overpayment the SSA then pursues. Trust drafting is a one-time event; disbursement compliance is a continuous, per-transaction need — and that gap is where the exposure lives.
BenefitGuard exists to close that gap with a single, exhaustive standard applied identically to every disbursement request, for the fiduciary to act on.
$2,000
the countable-resource limit a single mis-timed disbursement can breach
The benchmark
Measured against the letter of the POMS — provision by provision.
We do not summarize the rules and hope. Every request is scored against a versioned Rule Matrix tied to the exact text of the SSA POMS and the ABLE statute. These are the provisions each Determination Memo is held to.
Disbursement treatment
Whether a disbursement is treated as income or as in-kind support and maintenance for SSI purposes — classified against the payee and purpose, never assumed.
Presumed-maximum-value rule
The presumed-maximum-value rule caps the SSI reduction for in-kind support and maintenance at one-third of the FBR plus $20 — computed deterministically into the Benefit-Impact Projection.
Resource limit
The $2,000 individual countable-resource limit for SSI eligibility — screened against the beneficiary's current status before a request is cleared.
ABLE qualified expenses
ABLE accounts, qualified disability expenses, and the annual contribution cap tied to the federal gift-tax exclusion — tested for ABLE-funded disbursements.
Age-of-onset expansion
Effective 2026, ABLE eligibility raises the age of disability onset from before age 26 to before age 46 — applied by the beneficiary's onset facts, not query date.
How a memo is built
Submit to release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — screen each request against the Rule Matrix. A specialist releases every standard memo; novel and high-value cases route to a licensed attorney. That order is never reversed.
01
Disbursement Compliance Check
Send your first real disbursement request and within one business day get the same determination format, minus attorney sign-off — no pitch, no obligation to continue.
02
Submit
Send the disbursement description, amount, and payee; your beneficiary's current SSI/SSDI/Medicaid status and state; and the trust type or ABLE enrollment — the governing document is kept on file after your first submission.
03
Screen against the Rule Matrix
The request is screened deterministically against the versioned POMS and ABLE Rule Matrix — resource limit, income versus ISM, presumed-maximum-value, and qualified-expense tests — with every determination dated to the matrix version and facts submitted.
04
Project and restructure
A Benefit-Impact Projection quantifies any SSI effect, and a Restructuring Alternative is drafted where a safer path exists — for you to weigh, not a directive.
05
Release
A specialist releases every standard Determination Memo. Novel, high-value, or Certified Opinion cases route automatically to the attorney bench for a genuine licensed-attorney work product before delivery.
06
Delivery and Audit Trail
You receive the dated, cited Determination Memo and a full Audit Trail — the evidence of due diligence you need if a distribution is later questioned. You remain trustee and decision-maker of record.
The bar we hold
Rigor you can measure.
1 day
Standard turnaround
A dated, cited Determination Memo within one business day of a complete request.
100%
Specialist-released
No memo ships without a specialist's review; novel cases add licensed-attorney sign-off.
Versioned
Rule Matrix
Every memo is dated to the POMS/ABLE matrix version and the facts submitted.
Full
Audit Trail
Documented due diligence retained for every determination.
Why BenefitGuard
Built to be the most thorough option a fiduciary has.
Decision-ready, by design
The deliverable is a dated, cited determination with a benefit-impact projection and an audit trail — decision support you act on, with missing facts flagged, never invented.
Deterministic, not vibes
The gates that screen each request are code tied to the exact POMS and ABLE text, not a model's opinion — so a drafting error cannot slip past a resource limit or an ISM rule.
In its lane, on purpose
We provide benefits-compliance research to you as the professional-fiduciary customer of record — not legal advice to a beneficiary. Novel and high-value cases escalate to a licensed attorney; you make every determination.
Engagement
Flat fee, per request or per trust. Never hourly.
Simple and predictable, anchored just below published rush-fee precedent — decision support, not a cut of any distribution.
- A free Disbursement Compliance Check before you commit — the full determination format on your own first request, minus attorney sign-off.
- $45 standard / $95 rush per Disbursement Request, with the governing document kept on file after first submission.
- Portfolio Monitoring Retainer: $60 per trust per month, bundling up to 3 determinations.
- Certified Opinion: $350 flat licensed-attorney work product; Quarterly Portfolio Review from $500 per 25 trusts or accounts.
FAQ
Questions, answered precisely.
Is BenefitGuard practicing law?
No. BenefitGuard, a service of Your Deputy, Obuke LLC, provides benefits-compliance research delivered to you as the professional-fiduciary customer of record — not legal advice to a beneficiary or family. It is not a law firm. Novel, high-value, or Certified Opinion cases are reviewed and signed by a licensed elder-law attorney.
Do you take custody of funds or act as trustee?
Never. You remain trustee and decision-maker of record at all times, and BenefitGuard never acts as representative payee or SSA point of contact. We supply the compliance research and, where escalated, the licensed sign-off.
What if SSA later disagrees with a determination?
No compliance service can guarantee an agency's future finding, and we do not claim to. Every memo is dated to the Rule Matrix version and the facts submitted, with a full Audit Trail — the actual evidence of due diligence you need if a distribution is later questioned.
What happens with a novel or high-value request?
It routes automatically to our attorney bench for a Certified Opinion — a genuine licensed-attorney work product, priced as a flat $350 fee, never hourly.
How is this priced?
$45 standard / $95 rush per Disbursement Request; a Portfolio Monitoring Retainer at $60 per trust per month bundling up to 3 determinations; Certified Opinion at $350 flat; and Quarterly Portfolio Review from $500 per 25 trusts or accounts. Never hourly.
See the rigor on your own first request — before you approve it.
Start with a free Disbursement Compliance Check. Send one real disbursement request and we'll return a dated, cited determination format within one business day.
Benefits-compliance decision-support service · not legal advice · you remain trustee and make every determination.
[PLACEHOLDER] First-cohort disbursement-determination turnaround — our target is a 4-hour response window with 100% human-analyst sign-off on every determination, no exception. The real measured turnaround appears here once the first pilot trustees complete a cycle.
[PLACEHOLDER] First trustee/fiduciary reference — added only with a named pilot client's written permission. BenefitGuard never invents a testimonial or a beneficiary detail.
[PLACEHOLDER] Total disbursement determinations completed to date — a live, auditable count once real determinations have shipped, never estimated.